Case Digest (G.R. No. L-32052) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On December 14, 2010, the Supreme Court, in G.R. No. 176389, reversed the judgment of the Court of Appeals and acquitted the accused—Hubert Jeffrey P. Webb, Antonio Lejano, Michael A. Gatchalian, Hospicio Fernandez, Miguel Rodriguez, Peter Estrada, and Gerardo Biong—of the Vizconde murders for lack of proof beyond reasonable doubt. On December 28, 2010, private complainant Lauro G. Vizconde, an immediate relative of the victims, filed a motion for reconsideration, alleging that the Court had denied due process, misappreciated facts, maligned witness credibility (notably that of Jessica Alfaro), and committed grave abuse of discretion. Vizconde argued that the decision was tainted, resulted in miscarriage of justice, and demanded a fresh appraisal of evidence. He also questioned the Court’s treatment of defense evidence. In support, Vizconde cited Galman v. Sandiganbayan (228 Phil. 42, 1986), where acquittal was set aside for a sham trial. Additionally, four intervenors from Volu Case Digest (G.R. No. L-32052) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural History
- Hubert Jeffrey P. Webb, Antonio Lejano, Michael A. Gatchalian, Hospicio Fernandez, Miguel Rodriguez, Peter Estrada, and Gerardo Biong were charged with the Vizconde massacre and convicted by the Court of Appeals.
- On December 14, 2010, the Supreme Court, En Banc (7 Justices voting to acquit, 4 dissenting, 4 inhibiting), reversed the CA judgment and acquitted the accused for lack of proof beyond reasonable doubt.
- Motion for Reconsideration and Interventions
- On December 28, 2010, Lauro G. Vizconde, private complainant and immediate relative of the victims, moved for reconsideration, alleging: denial of due process; serious misappreciation of facts; erroneous credibility findings as to key witness Jessica Alfaro; miscarriage of justice; and grave abuse in evidence treatment.
- Motions to intervene were filed by:
- Fr. Robert P. Reyes, Sister Mary John R. Mananzan, Bishop Evangelio L. Mercado, and Dante L.A. Jimenez (Volunteers Against Crime and Corruption).
- Former Vice President Teofisto Guingona Jr.
Issues:
- Whether a motion for reconsideration of an acquittal decision is permissible without violating the constitutional prohibition against double jeopardy.
- Whether the allegations of due process violation, grave abuse of discretion, or a “tainted and erroneous decision” fall within the narrow exceptions allowing collateral attack on an acquittal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)